The 1916 Federal Employees’ Compensation Act doomed her case.

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A federal district court in Georgia has ruled that a law enacted by Congress over 100 years ago barred a lawsuit filed by a former employee at a medical center operated by the U.S. Department of Veterans Affairs in Augusta, Georgia, for injuries she allegedly suffered while working there.

The Case

Carolyn Stanley-Salters alleged that, on December 6, 2013, while working at the Charlie Norwood Veterans Affairs Medical Center, she was injured when a medical code cart fell on her. She asserted that the injuries she suffered forced her to retire early from her job and undergo corrective surgery.

On February 12, 2015, Ms. Stanley-Salters submitted a workers’ compensation claim to the U.S. Department of Labor’s Office of Workers’ Compensation Programs (“OWCP”).

The OWCP initially denied Ms. Stanley-Salters’ claim, but she appealed that decision to an OWCP hearing representative, who partially reversed the denial with respect to her claim for a lower back strain.

In letters dated February 24, 2016, the OWCP granted Ms. Stanley-Salters’ claim for medical payments arising from her back injury, but said that she would not receive continuation of pay benefits.

On January 25, 2018, Ms. Stanley-Salters sued the United States, seeking damages for her injuries.

The government moved to dismiss for lack of subject matter jurisdiction, arguing that Ms. Stanley-Salters’ acceptance of workers’ compensation benefits was the exclusive remedy for her injuries.

The District Court’s Decision

The district court granted the government’s motion to dismiss.

In its decision, the district court explained that, since 1916, the Federal Employees’ Compensation Act (“FECA”) has provided federal employees injured on the job with workers’ compensation benefits. Under the FECA, the district court observed, federal employees have the right to receive immediate benefits without needing to determine fault or engage in protracted litigation, but in return employees give up any right to sue the federal government.

Thus, the district court added, the FECA is an exclusive remedy, barring an employee from seeking further recourse against the federal government.

The district court also noted that, once the OWCP decides that a disability resulted from a workplace injury, “the claimant is limited to the remedies authorized by the FECA, even if a particular type of damage or consequence the claimant suffered is not compensable under the FECA.”

Moreover, the district court said, a decision by the OWCP on a claim can be appealed in three ways: (1) reconsideration by the district office; (2) a hearing before an OWCP hearing representative; or (3) appealing to the Employees Compensation Appeal Board. The district court pointed out that, “[n]oticeably absent from this list” was “any recourse in the federal courts.” The FECA was “the exclusive remedy for injured federal employees” and its decisions were “not subject to review by another official of the United States or by a court by mandamus or otherwise.”

Accordingly, the district court ruled, Ms. Stanley-Salters’ lawsuit was barred because she filed for and received workers’ compensation benefits under the FECA, and the injury underlying her court claim was the same injury that she was compensated for under the FECA.

To the extent that Ms. Stanley-Salters argued that she was entitled to lost wages for her absence from work due to injury, that argument failed, the district court concluded, because the OWCP had denied continuation of pay benefits and the district court lacked authority to review that decision.

Like most conventional narratives (about the court and otherwise), this one contains an element of truth but masks a much more complex, if subtle, pattern in its jurisprudence.

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